New Jersey PFAS Restrictions Expand Under Protecting Against Forever Chemicals Act

What The Law Restricts And When

For businesses selling into New Jersey, the most immediate planning point is the two-year compliance clock. From two years after the Act’s effective date, it will be unlawful to sell or distribute certain products that contain intentionally added PFAS. Covered categories include cosmetics, carpets, fabric treatments, and paper-based food packaging, subject to narrow allowances for trace contamination. The Act also includes a limited exemption for second-hand carpets and fabric treatments, which may matter for resale and refurbishment channels.

Cookware is treated differently. Where PFAS have been intentionally added to a handle or any food-contact surface, the product must carry a clear “This product contains PFAS” label in English and Spanish. The disclosure must also be presented in online listings, and products cannot be marketed as PFAS-free if PFAS have been intentionally added. These provisions extend compliance responsibility beyond manufacturing to importers, brand owners, distributors, and retailers managing product pages and claims.

Compliance Implications For Brands, Retailers, And Suppliers

New Jersey PFAS restrictions will require practical supply chain controls, not just legal review. Companies may need to distinguish intentionally added PFAS from trace contamination, then align procurement specifications, quality documentation, and marketing claims accordingly. Cosmetics brands may face reformulation choices, while packaging suppliers will need to review barrier coatings and grease-resistant treatments commonly associated with PFAS performance attributes.

Retailers and marketplace operators should also anticipate operational work. The law’s labelling requirements apply to packaging and online listings, so product content workflows may need updates to prevent inconsistent disclosures across channels. For multi-state portfolios, New Jersey’s approach may also influence broader harmonisation decisions, particularly where product lines already face PFAS scrutiny in other jurisdictions.

What To Watch From New Jersey DEP

The Act gives DEP a forward-looking role, including recommending additional PFAS-containing product categories for potential future bans and establishing a PFAS source-reduction programme and public education initiatives. It also mandates comprehensive PFAS monitoring and research across air, water, soil, and biota, supported by a USD 5 million appropriation. DEP is granted inspection, audit, and enforcement powers, including the ability to order non-compliant products off the market and impose civil penalties.

Summary

New Jersey’s Protecting Against Forever Chemicals Act strengthens oversight of intentionally added PFAS by setting product prohibitions and cookware labelling obligations on a two-year timeline. The law also expands DEP’s role in monitoring, research, and enforcement, with funding to support state-wide work. Businesses across cosmetics, textiles, packaging, and retail should begin PFAS mapping now.